1. INFORMATION WE MAY COLLECT AND PROCESS FROM YOU
• Information you give us: you may give us information about you by filling in forms on our site (our “Site") or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you enter our Site, search our Site, sign up to receive our newsletter and when you report a problem with our Site. The information you give us may include your name and e-mail address.
• Information we collect about you: with regard to each of your visits to our Site we may automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); content you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
2. WHAT WE DO WITH THE INFORMATION WE COLLECT
• The main reason we use this information is to provide you with both an improved website experience and details about our content and services, but we (or third party data processors, agents and sub-contractors acting on our behalf) may also use the information:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with information, goods and services that you request from us;
• to notify you about changes to our service;
• to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Site to ensure that content is presented in the most effective manner for you and for your computer, mobile device or other item of hardware through which you access our Site;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our Site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
• from time to time, we may also use your information to contact you for market research purposes.
• Where you have given us consent, we shall provide you with information about any new products, services, events, promotions, special offers and other information which we think will be of interest to you. You can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences at any time by contacting us as given in “Contacting us” above.
3. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
• We have a reciprocal data sharing agreement in place with our UK subsidiary, The Coaches Voice (UK) Ltd. Under the data sharing agreement we share personal information collected from you on the Site and by email as described in “Information we may collect and process from you” above.
• Under the data sharing agreement your personal information is only shared where it is necessary for our legitimate interests, such as the operation and administration of our business, and provided it does not override your interests and fundamental rights and freedoms as a data subject. The data sharing agreement also ensures that any personal information shared between The Coaches’ Voice Ltd and The Coaches’ Voice (UK) Ltd is processed in accordance with applicable data protection laws.
• We may share your information with selected third parties including:
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users; and
• Analytics and search engine providers that assist us in the improvement and optimisation of our Site.
• We may disclose your personal information to third parties on the following basis:
• where it is necessary to do so to provide our service to you and perform our obligations in accordance with any contract that we may have with you;
• where it is in our legitimate interest to disclose your personal information to third parties;
• where we have obtained your consent (where appropriate) to disclose your personal information to third parties;
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if all or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
4. WHERE WE STORE YOUR PERSONAL DATA & SECURITY OF YOUR PERSONAL DATA
• The data that we collect from you in the UK may be transferred overseas to Jersey. Jersey has received an adequacy ruling from the European Commission which has approved that its data protection law affords data subjects within the EEA equivalent rights and protection. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
• All information you provide to us is stored on our secure servers.
• We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
• Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5. HOW LONG WE KEEP YOUR INFORMATION
• We will keep your data for as long as necessary to fulfil the purposes described in this Policy or for as long as we are required by law.
6. YOUR RIGHTS
• Access to your information and updating your information: You have the right to access information which we hold about you. If you so request, we shall provide you with a copy of your personal information which we are processing. For any further copies which you may request, we may charge a reasonable fee based on administrative costs.
• You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (“data portability”).
• We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
• Right to object: You have the right to object to the processing of personal information as follows:
• Direct marketing: You have the right to object at any time to our processing of your personal information for direct marketing purposes.
• Where we process your information based on our legitimate interest: You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
• Your other rights: You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.
• In certain circumstances, you have the right to:
• request the erasure of your personal information erasure (‘right to be forgotten’);
• restrict the processing of your personal information to processing to which you have given your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of others.
7. EXERCISING YOUR RIGHTS
• You can exercise any of your rights as described in this Policy and under data protection laws by contacting us as given in “Contacting us” above.
• Save as described in this Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
• Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
• In order to improve the Site, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive. Please refer to our Cookies Policy for further information about the cookies we use and how you can manage them.
• Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
• You also have the right to complain to the Information Commissioner’s Office (https://ico.org.uk/) about our data processing activities (helpline on 0303 123 1113).
• Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this Policy.